Weyerhaeuser Company

Background Information on Weyerhaeuser's 1995 Flint River Air Permit

Fax Cover Sheet

Date: November 21, 1996
Time: 4:04 pm
To: Stan Melburg, DRA, EPA Region 4
Fax: 404-562-9961
From: Gary Risner
Phone: 404-881-5714
Fax: 404-881-5306

RE: Flint River 1995 Air Permit Discussion

Number of pages including cover sheet: 3

Message:

Stan, this discussion is provided as background information regarding the Flint River 1995 air permit application and also contains my twist on how the application compares to what would have happened under the FPA.

Please call if you would like to explore this approach further.

PSD COMPARISON: 1995 PERMIT vs. DUAL CAP APPROACH

In July 1995 Weyerhaeuser Flint River submitted an application to the Air Branch of the Georgia EPD to modify the existing Air Quality Permit. Weyerhaeuser was in the planning stages for implementing three innovative modifications to improve product quality and yield. Those modifications included the brownside optimization (listed in FPA), the utilization of anthraquinone as the processing aid, and a white liquor oxidation system (neither of which have been implemented).

Flint River calculated the baseline emissions prior to the proposed modifications (NRDC's Table A) and compared the baseline with the estimated potential emissions that would be generated after the proposed modifications. As part of the MIM strategy, Flint River first looked for emissions offsets to reduce or eliminate the increased emissions. Four energy savings projects were evaluated and used as emissions offsets for PSD avoidance. These energy saving projects are examples of the types of projects that Flint River will be examining during the energy conservation feasibility studies described in the FPA.

Had Weyerhaeuser not chosen to look for emissions reductions, a PSD review would indeed have taken place. The extra burden of this process would have required additional time and resources from Flint River, Georgia EPD, and EPA. One year later, the BACT analysis for the modified sources would have shown "no control," the modifications would have been approved, and emissions increases associated with higher boiler steaming rates would not have been reduced.

As described in the FPA, the dual emissions caps will provide the desired operating flexibility by allowing facility modifications (like the brownside optimization) that will have no appreciable increases in emissions but may utilize more of the major sources (boilers) available capacity. The dual emissions caps will not allow large emissions increases within the "facility emissions cap" (1995 actuals + PSD significant levels) nor allow modifications or changes in the method of operation under the "major source emissions cap."

The proposed FPA will provide flexibility in the future to run short term trials without going through the resource consuming permitting process. Two of the modifications listed in the permit application were trials which were not actually implemented at the facility. The modification that was implemented (brownside optimization) did not by itself cause air emissions increases above PSD significant levels. However, the energy conservation projects were implemented, and to date, the actual energy savings have been measured to be more than 40,000 lbs/hr of steam usage reductions.

The 1995 permit modification is not an example of the effectiveness of the PSD program, but it is a good example that clearly demonstrates the efficiencies that can be gained by the Agencies and Weyerhaeuser after implementing this FPA.

BROWNSIDE OPTIMIZATION WATER QUALITY IMPROVEMENTS

As part of the air permit application, Weyerhaeuser provided the Georgia EPD with a summary of the expected water quality improvements that Flint River could achieve after the completion of the brownside optimization. These improvements (listed on page 5 of NRDC's comments) were engineering projections and not commitments by Weyerhaeuser to enforceable water quality limits. While these projections may be the actual long term facility averages, customer demands may dictate otherwise. The FPA contains enforceable limits that Weyerhaeuser has committed to. The difference allows Flint River the operating flexibility to meet certain customer demands as necessary, and still demonstrate superior environmental performance.

Weyerhaeuser Company

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